ITI: Flexibility, engagement with industry and global alignment a must in implementing general-purpose AI models rules

Sep 18, 2024

BRUSSELS – ITI submitted comments to the EU AI Office consultation on the Code of Practice that will provide guidance on the implementation of the AI Act requirements on general-purpose AI (GPAI) models.

“The Code of Practice must be a flexible, balanced and effective tool that GPAI model providers can leverage to comply with their legal obligations under the AI Act while continuing to innovate,” said ITI’s Senior Policy Manager for Europe Marco Leto Barone. “To be successful, the drafting must pursue a flexible approach, a clear scope within the boundaries of the AI Act, alignment with global best practices and robust industry participation.”

As representative of leading GPAI Model Providers, downstream providers, deployers and other participants in the AI value chain, ITI made the following key points:

1. Flexibility is essential. With technology evolving as rapidly as GPAI does, setting overly prescriptive rules or mandating specific technical solutions could undermine the framework's effectiveness and stifle innovation.

2. Industry involvement is crucial. The Code of Practice will achieve its purpose if widely adopted by GPAI model providers to demonstrate compliance with their legal obligations under the EU AI Act. Therefore, drafting should incorporate experiences from GPAI model providers and include significant engagement with industry players.

3. The scope of the Code must remain clear: It is primarily a compliance tool and should not introduce new requirements for GPAI model providers or impose unforeseen obligations on downstream players.

4. Maintain consistency with global workstreams: Alignment with international efforts such as those within G7, OECD or at AI Safety Summits will promote regulatory interoperability across jurisdictions and support innovation. Consistency with voluntary industry standards is also important.